Regulatory Alerts2014-07-10 | Circular 5/2014 (BA) - Application of statements on Principle I, SolvV (old version) and GroMiKV (old version) to CRD IV and CRRCircular 5/2014 (BA) on the Application of Statements on Principle I, SolvV and GroMiKV to CRD IV and CRR
BaFin’s Circular 5/2014 clarifies that pre-2014 interpretative statements on Principle I, SolvV, and GroMiKV do not automatically apply to the newly recast CRD IV and CRR regulations. These legacy statements remain valid exclusively for transitional capital adequacy provisions under Article 500(1)(b) of the CRR until December 2017, while broader CRD IV implementation follows existing national administrative practice. Institutions must therefore evaluate whether specific interpretative letters align with the new regulatory framework or require amendment, particularly where EBA guidelines introduce substantive changes to transposed national law.
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